DRC-2013-003353 - 0901a068803cffc0

James Kuipers, PE
Principal Consulting Engineer
[e-mail]
Kuipers & Associates, LLC
PO Box 145
Wisdom, MT 59761
406-689-3464
"DRC-2013-003353"
October 21, 2013
OCT a 2013
O oS ad
To: Rusty Lundberg, Utah Division Radiation Control
From: Jim Kuipers P.E., Kuipers & Associates /
Re: Comments regarding Utah Division of Radiation Control's Proposed Licensing
Action to Amend State of Utah Radioactive Material License No. UT 1900479 to
Authorize the Receipt and Processing of Alternate Feed Material from Dawn
Mining Corporation's Midnite Mine.
The following comments are submitted on behalf of the Grand Canyon Trust ("Trust")
based on my review of the Utah Division of Radiation Control's ("Utah DRC") Proposed
Licensing Action to Amend State of Utah Radioactive Material License No. UT 1900479 to
Authorize the Receipt and Processing of Alternate Feed Material from Dawn Mining
Corporation's Midnite Mine. The comments are focused on the issue of the control of
fugitive dust resulting from the receipt, storage, and processing of the alternate feed
material at the White Mesa Mill ("Mill"). I support the comments filed by Grand Canyon
Trust, and submit additional comments as set out below. My qualifications to evaluate the
proposed licensing action are documented in my resume submitted as Appendix A.
The following comments are based on over 30 years of professional experience in the
mining and mineral processing industry as well as mining environmental practice. In
particular I have been involved in the design, implementation, operation and maintenance
of fugitive dust control measures at numerous mine/mill and water treatment sites
throughout the western U.S. including in Utah. I have been involved in the development of
best management practices related to dust control at Superfund sites such as the Anaconda
Smelter Superfund Site in Montana and am currently involved on behalf of several
governmental organizations in the development of dust control guidance for hardrock
mining and mineral processing sites.
These comments take the following approach to analyzing the adequacy of the proposed
license amendment: 1) Background on the proposed licensing action; 2) explanation of the
public and environmental health threats posed by fugitive dust from the alternate feed
material from the Midnite Mine site; 3) examples of best management practices for fugitive
dust control; 4) an evaluation and recommendation is made to assist Utah DRC to craft
license conditions that are adequately protective of public and environmental health.
l
I. Background
,jBased on;the Affidavit of Robert Nelson dated 13 October, 2010, Dawn Mining Corporation
is proposing to ship waste1 products from a Water Treatment Plant (WTP) located at their
Wellpinit, Washington facility. The WTP treats uranium contaminated mine water using a
pH adjustment process using hydrated lime which results in a precipitate or waste stream
that contains radium-226. Dawn Mining proposes to ship the waste stream to the White
Mesa Mill near Blanding, Utah for processing as alternate feed materials.
According to UTAH DIVISION OF RADIATION CONTROL, RADIOACTIVE MATERIALS LICENSE,
SUPPLEMENTARY SHEET, License #UT1900479, Amendment # 056 (License) the White
Mesa Mill is required to perform the following actions relative to fugitive dust which might
be generated from receiving, storage and processing of the proposed waste materials:
10.20 ... The Licensee is authorized to receive no more than 1,000 tons per year and a total
limit of 4,500 tons (dry weight)...
A. (1) Dawn Mining Uranium Material stored (stockpiled) at the Mill Site longer than
14 days shall be covered with a durable geomembrane cover resistant to damage by
ultraviolet (UV) radiation and sufficient ballast shall be placed over the cover to prevent
wind uplift of the cover during peak wind conditions at the site; and
(2) If at any time, visible dust is observed to be originating from Uranium Material stored
on site, the EFRI RSO or his or her authorized representative shall take actions within 30
minutes to stop the generation of visible dust."
License Conditions 10.20 (A)(1) and (A)(2) do not adequately protect public and
environmental health from the fugitive dust hazards posed by the alternate feed from the
Midnite Mine site. Contrary to the Utah Radiation Control Rules, Utah DRC does not
institute fugitive dust controls adequate to meet the "as low as reasonably achievable"
occupational dose standard mandated in the Utah Admin. Code. Utah Admin. Code R313-
15-101(2). These comments will demonstrate that there are recognized best management
practices (BMPs) that Utah DRC should consider as "reasonably achievable" in use at other
sites. Utah DRC could and should mandate the use of the technology referenced in these
comments to control fugitive dust resulting from the Midnite Mine alternate feed material
at the Mill as part of its duty to in order to adequately protect public and environmental
health. See Utah Admin. Code R313-12-2. (The general purpose of the radiation rules is "to
ensure maximum protection of the public health and safety to all persons at, or in the
vicinity of, the place of use, storage, or disposal."); Utah Admin. Code R313-22-33 (Director
shall approve an amendment to a radioactive material license if "the Director determines
that... (b) the applicant's proposed equipment, facilities, and procedures are adequate to
minimize danger to public health and safety or the environment, (standards applied to
license amendments by Utah Admin. Code R313-22-39)).
2
II. Hazards Posed by Fugitive Dust From the Midnite Mine Alternate Feed Material
As the Utah Division Radiation Control is well aware, fugitive dust represents a significant
impact both to public health and to general public welfare in the following ways:
• Threatens physical injury to the public with chronic lung disease, asthma and other
lung related illness;
• Significant detriment, nuisance or annoyance to the public;
• Cause injury or damage to business or property;
• Create hazardous conditions on public right of ways; and
• Cause blight and impairment of property values and development opportunity.
While it is not the focus of our area of expertise, we have a great deal of knowledge with
respect to the undesirable nature of fugitive dust from a public health and socio-economic
impact standpoint, as well as its mitigation from an engineering and regulatory standpoint.
III. Fugitive Dust Control Plans Currently Utilized at Other Sites
The primary area of concern relates to the nature of the waste stream and the
implementation of best management practices (BMPs) related to the proper receiving,
storage and disposal of the waste materials. Although no specific information is provided
in the License, WTP waste streams from lime precipitation processes are typically highly
amorphous (e.g. water containing) and consist of extremely fine grained precipitates and
water in varying proportions. Unfiltered or settled WTP waste streams from similar
processes typically contain <5% solids, while settled waste streams contain up to 20%
solids, and filtered waste streams may contain up to 80% solids.
The licensee should be required to provide additional information as to the nature of the
waste materials to be received. Although 1,000 tons per year of dry solids may not appear
to be a significant amount of material, if the waste stream were unfiltered and shipped in
55 gallon drums at 5% solids approximately 14,545 barrels would be shipped and stored.
With 50% solids more than 1,455 barrels would still require shipment and storage as well
as proper disposal. The License, in requiring in 10.20 A. (1) that material stored or
stockpiled be covered with a durable geomembrane cover, gives the impression that the
material may be received in trucks or containers and dumped at the site. The License
should more specifically identify the types of materials to be received (e.g. unfiltered,
settled or filtered waste materials), the percentage of dry contents, and the nature of the
shipping containers or methods to be utilized or allowed.
The License should require the licensee to take every reasonable precaution not to cause or
allow the emissions of fugitive dust from being airborne while in transit to the site. The
Draft Utah Division of Air Quality Fugitive Dust Control Plans Instructions, available at:
http.y/wvw.airqualitv.uta^^
ctions%2012-12.pdf contain the following requirements:
3
The Fugitive Dust Rule (R307-309) requires a fugitive dust control plan (R307-309-6) from all
sources whose activities or equipment have the potential to produce fugitive dust (airborne
dust) in PM10 and PM2.5 non-attainment areas. Fugitive dust control plans include steps your
company will take to minimize fugitive dust on-site from pits, yards, storage areas, and areas
of operation and to prevent opacities caused by fugitive dust from exceeding 20% on site and
10% at the property boundary. The fugitive dust rule addresses storage and handling of
aggregate materials, construction and demolition activities on sites greater than 1/4 acre,
road ways and tailings piles and ponds. Sources shall develop\theirfugitive dust control plans
and submit them to the Director prior to the start of clearing or construction. Fugitive dust
control plans, tailored to specific operations and sites of operation, shall be required for:
1. All operations with material storage, handling and/or hauling operations and areas of
source operations, construction sites; and all sources or operations which have the potential
to produce fugitive dust in nonattainment areas along the Wasatch Front;
2. All temporary relocations under R307-401-17. Sources will be required to develop a site
specific fugitive dust control plan for each temporary relocation of permitted equipment;
3. All sources and areas of source operations, pits and yards, statewide, which have been
issued a Compliance Advisory for excess fugitive dust. Operations, areas of operation and
sources that shall be addressed in fugitive dust control plans are:
• material storage/handling - drilling, blasting, and pushing operations
• material handling/transfer - clearing/leveling/development construction
• material processing/transfer - earth moving and excavation
• road ways and yard areas - track out/spillage on paved roads
• loading/hauling/dumping materials - exposed surfaces
These requirements are also consistent with the fugitive dust controls that are commonly
used by the mining industry as well as that part of the mining industry that deals with WTP
waste materials. Those practices are also consistent with regulatory and permitting
requirements in Nevada, Wyoming, Montana, Colorado, Idaho and North Dakota according
to the National Mining Association
(http://www.nma.org/pdf/pol briefs/041906 naaqs snapshot.pdfl;
Moreover, these requirements have been implemented at sites near the Mill in Utah. See
Moab Project Site Fugitive Dust Control Plan (March 2002) (Trust Comments Exhibit 1);
Crescent Junction Project Site Fugitive Dust Control Plan (July 2006) (Trust Comments
Exhibit 2).
IV. Recommendations
The License should, at a minimum, require similar measures to those documented above to
minimize fugitive dust emissions at the White Mesa Mill from the proposed Dawn Mining
waste stream materials. These should specifically include the following:
• Identification of the nature of the waste materials in terms of the physical properties
of the materials transported to and received at the site.
4
Measures to ensure fugitive dust control from material transport from Dawn Mining
to the White Mesa Mill;
Measures to ensure fugitive dust control during material receiving including during
discharge of the material from trucks, containers or drums into the receiving area:
Measures to immediately assure that materials are covered to prevent drying and
increase susceptibility to blowing wind as well as to prevent flowing of dried
materials:
o This should include a windbreak to prevent offsite migration of radionuclide
laden dust around the storage pads.
o There is no reason why BMPs should not be implemented on an immediate
basis at the site. The 14 day window is not consistent with modern practice
of control measures to protect worker and public safety.
Measures to assure that materials are handled for processing in a manner so as to
minimize fugitive dust:
Development as a part of the License of a site-specific fugitive dust control plan
including identification of additional measures and assurance that those measures
can be implemented in a safe and timely manner.
o The fugitive dust control plan should include fugitive dust standards, action
levels, response actions, and real time meteorological and dust monitoring
during periods of high winds, and work practice standards for mitigating
wind dispersion of differing waste materials based on density estimates of
those materials.
These recommendations are standard practice where similar situations are encountered
and are both practical and reasonable. They benefit public health without being overly
burdensome as evidenced by their routine use in Utah as well as at many other locations in
the United States. The lack of more specific measures in the present License is not
consistent with current industry or regulatory practice.
Finally, in the larger context these same requirements and standards should be applied to
the White Mesa Mill site as a whole. I have been involved in the mining industry, including
working for Energy Fuels as a miner in 1979. The White Mesa Mill has a long and
unfortunate history relative to fugitive dust emissions, which I need not elaborate on.
However, as a professional engineer involved in similar manners, failure to utilize modern
BMPs to control fugitive emissions is evident at the site. This is despite significant advances
and acceptance by industry of BMPs that are both effective and economical. I strongly
encourage the Utah Division of Radiation Control to similarly recognize this situation as
well as the Licensee and take the necessary measures to responsibly rectify this situation.
5
/
Appendix A
JAMES R. KUIPERS, P.E.
P.O. Box 641, Butte, MT 59703
Phone [phone]
[e-mail]
SUMMARY OF EXPERIENCE
Over 30 years experience in mining and environmental process engineering design, operations
management, regulatory compliance, waste remediation, reclamation and closure, and financial assurance.
Over 15 years experience providing technical assistance to public interest groups and tribal, local, state and
federal governments on technical aspects of mining and environmental issues.
EDUCATION
Montana College of Mineral Science and Technology, B.S. Mineral Process Engineering, 1983.
PROFESSIONAL REGISTRATION
Professional Engineer (PE Mining/Minerals): Colorado (No. 30262), Montana (No. 7809 & Corp. No. 197)
PROFESSIONAL EXPERIENCE
1996 to Present Kuipers & Associates/J. Kuipers Engineering, Butte, MT.
• ABNAMRO Bank, Netherlands. Consulting Engineer, confidential mine evaluation.
• Amigos Bravos, Taos, NM. Consulting Engineer, Molycorp Questa Mine, technical review committee
and working group member in reclamation and closure/closeout permitting and bonding process.
• Anaconda Deer Lodge County, MT Consulting Engineer/Project Manager, Anaconda Superfund Site,
provide technical services related to institutional controls, property conveyance and redevelopment,
property and facility operation and maintenance, review of regulatory documents, renewable energy
development, air and water monitoring and other tasks related to county involvement in Superfund
activities.
• Bannock Technologies, Pocatello, ID. Consulting Engineer, Shoshone Bannock Tribe mining oversight
project studies.
• Blackfoot Legacy, Lincoln, MT: Consulting Engineer, McDonald Project, review of project feasibility and
environmental issues.
• Border Ecology Project, Santa Fe, NM: Consulting Engineer, Cananea Project (Mexico), consulting
engineer mine reclamation and closure planning.
• Cabinet Resource Group, Noxon, MT. Consulting Engineer, Rock Creek Project, review of proposed
tailing impoundment.
• Clark Fork River Technical Advisory Committee, Missoula, MT. Technical Advisor, Clark Fork River
and Milltown Reservoir Operable Units, Upper Clark Fork Basin Superfund Sites.
JAMES R. KUIPERS, PE (Page 1)
• Center for Science in Public Participation, Bozeman, MT: See separate description below.
• Citizens' Technical Environmental Committee, Butte, MT: Technical Advisor, Butte-Silver Bow Site
Operable Units, Upper Clark Fork Basin Superfund Sites.
• Cottonwood Resource Council, Big Timber, MT: Consulting Engineer, Lodestar Mine and Mill, review
of operating and MPDES permits, financial assurance and operations data.
• Earthjustice, Bozeman, MT: Consulting Engineer, Montanore and Rock Creek Projects permitting
process.
• Earthworks, Washington, D.C.: Project Manager and co-author, Water Quality Predictions and
NEPA/EIS Studies.
• Environmental Defender Law Center, Bozeman, MT. Expert Witness and Consulting Engineer, Boliden
Promel, Chile arsenic waste disposal.
• Gila Resources Information Project, Silver City, NM: Consulting Engineer, Phelps Dodge Chino, Cobre
and Tyrone Mines, reclamation and closure/closeout permitting and bonding process.
• Great Basin Mine Watch, Reno, NV: Expert Witness and Consulting Engineer, various NV projects,
permitting and reclamation and closure/closeout permitting and bonding process.
• ICF International, Stafford, VA: Consulting Engineer, 108(b) rulemaking technical support contract
including financial assurance cost estimation model evaluations.
• Johnson County, KS: Consulting Engineer, Sunflower Limestone Mine reclamation plan and financial
assurance.
• Little Salmon Carmacks First Nation, Yukon Territory, Canada. Expert Witness and Consulting
Engineer, Carmacks Copper Project.
• Montana Attorney Generals Office, Helena, MT: Consulting Engineer, assist in defense of 1-137 Open
Pit Cyanide Mine Ban appeals.
• Montana Department of Environmental Quality, Helena, MT. General Contractor, Pony Mill Site
Reclamation.
• Montana Environmental Information Center, Helena, MTand National Wildlife Federation, Missoula,
MT. Expert Witness and Consulting Engineer, Golden Sunlight Mine, EIS Review and assist appeal of
State operating permit.
• Montana Environmental Information Center, Helena, MT. Expert Witness, Bull Mountain Coal Mine
appeal.
• Montana Trout Unlimited, Missoula, MT. Consulting Engineer, Trout Unlimited's Four Mines Campaign,
review and provide technical assistance on McDonald, Crandon, New World and Rock Creek Mines.
• Natural Resources Defense Council, New York State: Consulting Engineer, review of Oil & Gas Draft
EIS.
JAMES R. KUIPERS, PE (Page 2)
• New Mexico Environmental Law Center, Santa Fe, NM. Consulting Engineer, Oglebay Norton Mica
Mine reclamation and financial assurance; New Mexico Environment Department Copper Rules
Stakeholder Process.
• Northern Plains Resource Council, Cottonwood Resource Council, Stillwater Protective Association,
Billings. MT: Consulting Engineer, Stillwater Mining Company Nye and East Boulder Mines, facilitate
and perform technical aspects of Good Neighbor Agreement.
• Northern Plains Resouce Council, Billings, MT; Wyoming Outdoor Council, Sheridan, WY: Consulting
Engineer, Montana Statewide and Wyoming Powder River Basin Coal Bed Methane EIS.
• Northern Plains Resouce Council, Billings, MT: Project Manager and co-author, Coal Bed Methane
Produced Water Studies.
• Northern Alaska Environmental Council, Fairbanks, AK: Consulting Engineer, Pogo Mine NPDES
permit negotiations.
• Picuns Pueblo, Penasco, NM: US Hill Mica Mine Reclamation Plan and financial assurance cost
estimate and site reclamation project management.
• Powder River Basin Resource Council, Sheridan, WY/Steven Adami, Buffalo, WY: Expert Witness,
Kennedy Oil IMADA POD appeals.
• Rock Creek Alliance, Missoula, MT: Expert Witness and Consulting Engineer, Rock Creek and
Montanore Mines permitting.
• Selkirk First Nation, Yukon Territory, Canada: Expert Witness and Consulting Engineer, Minto Mine
Project reclamation and closure and financial assurance.
• Sheep Mountain Alliance, Telluride, CO. Expert Witness and Consulting Engineer, Silver Bell Tailings
remediation.
• Shoshone-Paiute Tribes of the Duck Valley Reservation, NV: Consulting Engineer, Rio Tinto Mine
Reclamation and Closure.
• Sierra Club and Mineral Policy Center: Expert Witness, Cripple Creek and Victor Mining Company
Clean Water Act case.
• SKEO, Charlottesville, VA Consulting Engineer, 108(b) rulemaking technical support contract and EPA
Region NEPA review and financial assurance support.
• Southern Environmental Law Center, Charleston, SC. Consulting Engineer, Haile Gold Mine
permitting.
• Systems Research and Applications Corporation, Fairfax, VA: Consulting Engineer, mine cleanup and
financial assurance guidelines subcontract to EPA.
• Montana Trout Unlimited, Missoula, MT: Consulting Engineer, 1-147 initiative campaign.
JAMES R. KUIPERS, PE (Page 3)
• Tohono O'odham Nation, San Xavier District, AZ: Consulting Engineer, Mission Mine reclamation plan
and financial assurance.
• Trust for Public Lands, San Francisco, CA: Consulting Engineer, Viceroy Castle Mountain Mine,
evaluated pit backfill and reclamation alternatives for settlement agreement trust fund determination.
• Walz and Associates, Albuquerque, NM: Expert Witness and Consulting Engineer, assist in defense of
New Mexico Environment Department and Mining and Minerals Division permitting and takings case
(Manning v. NM).
• Western Organization of Resource Councils, Billings, MT: Oil and gas reclamation and financial
assurance guide.
• Western Resource Advocates, Salt Lake City, UT. Expert Witness and Consulting Engineer, Red Leaf
Resources oil shale project permitting.
1997 to 2005 Center for Science in Public Participation, Bozeman, MT.
• Canadian Earthcare Society, Vancouver, BC. Consulting Engineer, Brenda Mine, assist appeal of
reclamation and closure permit.
• CEE Bankwatch, Budapest, Hungary. Consulting Engineer, Rosario Montana Mine (Romania),
economic feasibility study of mine proposal.
• Friends of the Similkameen, Hedley, BC. Consulting Engineer, Candorado Mine, assist appeal of
reclamation and closure permit.
• Fort Belknap Tribal Council and Environment Department, Fort Belknap.MT. Consulting Engineer,
Zortman and Landusky Mines, Alternative Reclamation and Closure Plan, multiple accounts analysis
working group member and technical advisor during supplemental environmental impact statement.
• Guardians of the Rural Environment, Yarnell, AZ: Consulting Engineer, Yarnell Project, EIS review and
assist appeal of State operating permit.
• Mineral Policy Center, Washington, D. C: Technical Advisor on general mining issues and Author of
MPC Issue Paper.
• National Wildlife Federation, Boulder, CO. Consulting Engineer authoring report on Hardrock Mining
Reclamation and Closure Bonding Practices in the Western United States.
• Sakoagan Chippewa Tribes, Mole Lake Reservation, Wisconsin. Consulting Engineer, Crandon
Project, permitting process review.
1993 -1995 Denver Mineral Engineers, Inc., Littleton, CO.
• Manager, Process Engineering Department.
• Manager, Mining and Environmental Wastewater Treatment Program
JAMES R. KUIPERS, PE (Page 4)
• Arrowhead Industrial Water Co., San Jose, CA. Project Manager, evaluation of reverse osmosis for
mine wastewater treatment.
• Barrick Goldstrike, USA, Elko, NV. Project Engineer, engineering design, construction and installation
of 1.5 M oz/year stainless steel electrowinning system.
• Battle Mountain Gold, Co., Battle Mountain, NV. Project Manager, evaluation, pilot testing, and
preliminary feasibility study of wastewater treatment options for groundwater remediation of Fortitude
Mine tailings area.
• Commerce Group Corporation, Milwaukee, Wt. Project Manager, San Sebastian Gold Project, El
Salvador.
• Independence Mining Corp, Jerritt Canyon, NV. Project Manager, technical evaluation and feasibility
study of column flotation for beneficiation of refractory ores.
• Kennecott Utah Copper, Bingham Canyon, UT. Project Manager, design and construct stainless steel
solvent extraction mixer settlers for prototype SX/EW plant.
• Israeli Chemical Corp., Beersheeba, Israel. Project Manager, evaluation of bromine as an alternative to
cyanide gold leaching and prototype design.
• Marston and Marston, St Louis, MO. Project Manager, Kommunar Gold Mill Modernization Project,
Kommunar, Siberia, Russia (CIS) and Suzak Polymetal Leach Circuit Evaluation and Feasibility Study,
Kazakhstan (CIS).
• Nevada Goldfields Mining Co., Denver, CO. Project Manager, Nixon Fork Mine Preliminary
Engineering Design and Feasibility Study, Concentrate Marketing Study, and environmental permitting
studies.
• Southern Pacific Railroad, Denver, CO. Project Manager, design, construction and installation of
dissolved air flotation wastewater treatment system.
1991 -1992 Western States Minerals Corp.
• Project Manager, Northumberland Gold Mine, Round Mountain, NV.
• Corporate Senior Metallurgist, Wheat Ridge, CO. Engineering design and feasibility evaluations.
1986 -1991 Western Gold Exploration and Mining Co. (WESTGOLD)/Minorco
• Corporate Senior Metallurgist / Project Manager, WESTGOLD, Golden, CO. Acquisitions and
engineering design and feasibility evaluations, corporate acquisitions and business development group.
• Project Manager, Shamrock Resources (WESTGOLD Subs.), Reno, NV. Evaluation, engineering
design and feasibility study, and prototype plant operation of refractory gold ore bioleaching technology
program.
• Project Manager, Balmerton Mine, Ontario: Refractory gold ore bioleaching project and feasibility
evaluation.
JAMES R. KUIPERS, PE (Page 5)
• Project Engineer, Johannesburg South Africa: Evaluation of Anglo American Corp. Pumpcell
Technology.
• Mill Superintendent, Austin Gold Venture (WESTGOLD), Austin, NV.
• Shift Foreman, Inspiration Consolidated Copper Co, Globe, AZ.
1984 -1985 Canyonlands 21 st Century Corporation
• Director of Metallurgy, Blanding, UT. Project Manager, Jarbidge, NV.
1983 -1984 Cumberland Mining Corporation
• Mill Superintendent / Head Metallurgist, Basin and Virginia City, MT.
1974 -1980 Huckaba Construction
• Summer employment as Underground and Surface Miner, Millwright, Mill Operator, Fire Assayer,
Whitehall and Cooke City, MT. Family owned small mining operation.
PRESENTATIONS and PUBLICATIONS
• Financial Assurance Regulations and Cost Estimation at US Hardrock Mines, U.S. Chile Mining
Financial Assurance Seminar, US Office of Surface Mining and Environmental Protection agency and
Chilean Ministry of Mining, Santiago, Chile, May 2012.
• Mining Reclamation and Closure Regulations and Best Practices, 2012 International Conference on
Mining in Mindanao, Ateneo de Davao University, Davao City, Philippines, January 26-27,2012.
• Beyond the Global Acid Rock Drainage Guide, Lake Superior Binational Program, Mining in the Lake
Superior Basin Webinar Series, Environmental Impacts of Mining in the Lake Superior Basin, October
27,2009
• Characterizing, Predicting, and Modeling Water at Mine Sites, California Environmental Protection
Agency, California Water Board Training Academy, May 18 - 21,2009
• Mitigating Mining Impacts: Principles and Practices, Lake Superior Binational Program, Mining in the
Lake Superior Basin Webinar Series, Environmental Impacts of Mining in the Lake Superior Basin,
March 24,2009
• Long-term Requirements & Financial Assurance at Superfund & Other Mine Sites, Mine Design,
Operations and Closure Conference, Fairmont Hot Springs, MT, April 2008.
• The Effects of Coalbed Methane Production on Surface and Ground Water Resources, Committee on
Earth Resources, Board on Earth Sciences and Resources, National Research Council, Meeting on the
Status of Data and Management Regarding the Effects of Coalbed Methane Production on Surface and
Ground Water Resources, Denver, Colorado, April 2008.
JAMES R. KUIPERS, PE (Page 6)
• Reclamation Planning and Financial Assurance Practice in the United States, Kamchatka Mining
Conference, Kamchatka Oblast People's Council of Deputies, the Committee on Ecology and Resource
Management of Kamchatsky Krai, the Rosprirodnadzor Division of Kamchatka Oblast and Koryaksky
Autonomous Okrug, the Division for Minerals Management for Kamchatka Krai, and the Kamchatka
Oblast Council of the All-Russia Society for Nature Protection, Petropavlovsk-Kamchatsky, Russia,
October 2007.
• The Good Neighbour Agreement: A Proactive Approach to Water Management through Community
Enforcement of Site-Specific Standards, w Sarah Zuzulock, Greener Management International, Issue
53, Spring 2006, Greenleaf Publishing. 2007.
• Sustainable Development at the Anaconda Superfund Site, Mine Design, Operations and Closure
Conference, Fairmont Hot Springs, MT, April 2007.
• Comparison of Predicted and Actual Water Quality at Hardrock Mines: The reliability of predictions in
Environmental Impact Statements with A. Maest, K. MacHardy, G. Lawson. Predicting Water Quality at
Hardrock Mines: Methods and Models, Uncertainties, and State-of-the-Artw\\h A. Maest, Final Report
Release December 2006.
• Reclamation and Bonding in Copper Mining, U.S. EPA Hardrock 2006: Sustainable Modern Mining
Applications, Tucson, Arizona, November 2006.
• Sustainable Development at the Anaconda Superfund Site: U.S. EPA Hardrock 2006: Sustainable
Modern Mining Applications, Tucson, Arizona, November 2006.
• US. Perspective on Financial Assurance for Mine Cleanup, presented at International Bar Association
Conference, Chicago, Illinois, September 2006.
• Comparison of Predicted and Actual Water Quality at Hardrock Mines: The reliability of predictions in
Environmental Impact Statements with A. Maest, K. MacHardy, G. Lawson, presented at Mine Design,
Operations and Closure Conference, Fairmont Hot Springs, MT, April 2006.
• Predicted Versus Actual Water Quality at Hardrock Mine Sites: Effect of Inherent Geochemical and
Hydrological Characteristics with A. Maest, K. MacHardy, and G. Lawson at International Congress on
Acid Rock Drainage (ICARD), March 2006, St. Louis, MS.
• Oil, Gas and Coal Bed Methane Reclamation and Financial Assurance Guide, with Kimberley
MacHardy and Victoria Lynne, November 2005; 12th International Petroleum Environmental
Conference, Houston, TX.
• Approaches to Abandoned Mine Site Assessment and Remedy Selection in the U S., NOAMI
Workshop on Assessing Liabilities and Funding Options, November 2,2005 Ottawa, Canada
• Filling the Gaps: How to Improve Oil and Gas Reclamation and Reduce Taxpayer Liability, Kuipers &
Associates for Western Organization of Resource Councils, August 2005.
• The Environmental Legacy of Mining in New Mexico, Mining in New Mexico: The Environment, Water,
Economics and Sustainable Development, New Mexico Bureau of Geology and Mineral Resources,
Decision-Makers Field Conference 2005, L. Greer Price et al Editors.
JAMES R. KUIPERS, PE (Page 7)
Financial Assurance and Bonding, 2005 Decision-Makers Field Conference, Mining in New Mexico:
The Environment, Water, Economics and Sustainable Development, New Mexico Bureau of Geology
and Mineral Resources, May 2005.
E valuation of the NEPA Process for Estimating Water Quality Impacts at Hardrock Mine Sites with A.
Maest, K. MacHardy, G. Lawson, for Earthworks, presented at Society of Mining Engineers Annual
Conference, Salt Lake City, UT, March 2005 and Mine Design, Operations and Closure Conference,
Poison, MT, April 2005.
Evaluation of Methods and Models Used to Predict Water Quality at Hardrock Mine Sites: Sources of
uncertainty and recommendations for improvement with A. Maest, C. Travers and D. Atkins, for
Earthworks, presented at Society of Mining Engineers Annual Conference, Salt Lake City, UT, March
2005 and Mine Design, Operations and Closure Conference, Poison, MT, April 2005.
Coal Bed Methane-Produced Water: Management Options for Sustainable Development, co-authored
with K. MacHardy, W. Merschat and T. Myers, presented at Coal Bed Natural Gas Research,
Monitoring and Applications Conference, Laramie, WY, August 2004; 11th International Petroleum
Environmental Conference, Albuquerque, NM, October 2004; Northern Plains Resource Council Annual
Meeting, November 2004.
Technology-Based Effluent Limitations for Coal Bed Methane-Produced Wastewater Discharges in the
Powder River Basin of Montana and Wyoming, Northern Plains Resource Council, Billings, MT,
November 2004.
Financial Assurance Guidelines for Hardrock Mine Cleanup, Mine Design, Operations and Closure
Conference, Poison, MT, April 2004.
Introduction to Mine Water Treatment, Mine Discharge Water Treatment Short Course, Mine Design,
Operations and Closure Conference, Poison, MT, April 2004.
Coal Bed Methane: A Design and Process Overview of Production and Produced Water, presented as
short course at Joint Engineers Conference, Helena, MT, November 2003.
The Good Neighbor Agreement between Stillwater Mining Company and Northern Plains Resource
Councils: An Example of Industry and Citizen Cooperation, presented as a short course at Joint
Engineers Conference, Helena, MT, November 2003.
Reclamation and Financial Assurance for Mines on or Impacting Tribal Land, presented at U.S. EPA
Workshop on Mining Impacted Native American Lands, Reno, NV, September 2003.
Reclamation and Financial Assurance from a Public Interest Perspective, presented at U.S. Forest
Service National Geofest, Park City, UT, September 2003.
U.S. State and Federal Policies on Financial Assurance Forms for Hardrock Mines, presented at New
Mexico Financial Assurance Forum, Santa Fe, NM, May 2003.
Public Interest Perspective on Land Application Disposal, presented at Mine Design, Operations and
Closure Conference, Poison, MT, April 2003.
JAMES R. KUIPERS, PE (Page 8)
Putting a Price on Pollution: Financial Assurance for Mine Reclamation and Closure, Mineral Policy
Center, Washington, D.C., March 2003.
Testimony to the Subcommittee on Energy and Mineral Resources, Committee on Resources, U.S.
House of Representatives, Hearing on "Availability of Bonds to Meet Federal Requirements for Mining,
Oil and Gas Projects." Washington, D.C., July 23,2002.
Mine Closure and Financial Assurance: Can the Mining Industry Afford It's Legacy?, presented at
Global Mining Initiative Conference, Toronto, Canada, May 2002.
The Role of the Center for Science in Public Participation in Mining Environmental Issues, with
Perspective for Regulators and Industry, presented at Canadian Institute of Mining and Metallurgical
Engineers Conference, Vancouver, Canada, May 2002 and U.S. EPA Hardrock Mining Conference,
Denver, Colorado, May 2002.
The Good Neighbor Agreement between Stillwater Mining Company and the Northern Plains Resource
Councils: The Formation and Implementation of a New Approach to Addressing Environmental and
Community Relations Issues, presented at U.S. EPA Hardrock Mining Conference, Denver, Colorado,
May 2002.
Underground Hard-Rock Mining: Subsidence and Hydrologic Environmental Impacts, Center for
Science in Public Participation, Bozeman, MT, February 2002. Co-authored with S. Blodgett.
Review of the Multiple Accounts Analysis Alternatives Evaluation Process Completed for the
Reclamation of the Zortman and Landusky Mine Sites, presented at National Association of Abandoned
Mine Lands Annual Conference, Athens, Ohio, August 2001. Co-authored with S.C.Shaw, A.M.
Robertson, W.C. Maehl and S. Haight.
Full Reclamation and Closure Plan, Phelps Dodge Tyrone Mine, Grant County, NM; GWa Resources
Information Project, Silver City, NM, July 2001. Co-authored with S. Blodgett.
Reclamation Bonding for Hardrock Metal Mines Workshop, presented by CSP2 at Juneau and
Fairbanks, AK, July 2001.
Full Reclamation and Closure Plan, Phelps Dodge Chino Mine, Grant County, NM; Gila Resources
Information Project, Silver City, NM, June 2001. Co-authored with S. Blodgett.
Reclamation Bonding in Montana; Montana Environmental Information Center, Helena, MT, November
2000. Co-authored with S. Levit.
Full Reclamation and Closure Plan, Molycorp Questa Mine, NM; Amigos Bravos, Taos, NM, May 2000.
Hardrock Mining Reclamation and Bonding Practices in the Western United States. National Wildlife
Federation, Boulder, CO, February 2000.
An Economic Evaluation of the McDonald Gold Project, Blackfoot Legacy, Lincoln, MT, February 2000..
Restoring the Upper Clark Fork: Guidelines for Action, Trout Unlimited, Missoula, MT, April 1999. Co-
authored with D. Workman, B. Farting and P. Callahan.
JAMES R. KUIPERS, PE (Page 9)
Alternative Final Reclamation and Closure Plan, Zortman and Landusky Mines, MT: Indian Law
Resource Center, Helena, MT, January 1999.
Reclamation Bonding Regulations of Precious Metal Heap Leach Facilities in the Western United
States: Presented at the workshop on Closure, Remediation and Management of Precious Metals
Heap Leach Facilities, University of Nevada, Reno, Jan 15,1999.
Wastewater Treatment Methods for Base and Precious Metal Mines. Public Education for Water
Quality Project, Northern Plains Resource Council, Billings, MT, 1996.
Bacterial Leaching Pilot Study - Oxidation of a Refractory Gold Bearing High Arsenic Sulphide
Concentrate: Randol Gold Forum, Squaw Valley, 1990. Co-authored with J. Chapman, B. Marchant,
R. Lawrence, R. Knopp.
Novel Aspects of Gold Recovery Using Column Flotation at Austin Gold Venture. Gold and Silver
Recovery Innovations, Phase IV Workshop, Randol International Ltd, Sacramento, CA, 1989.
JAMES R. KUIPERS, PE (Page 10)